Data protection is more than having a privacy policy on your website. Organisations that collect, use, store or share personal information need to understand their responsibilities and have the right processes, expertise and oversight in place to protect that information.

For some organisations, maintaining this expertise internally can be challenging. This is where DPO-as-a-Service can offer a practical solution. Under Section 70(2) of Botswana’s Data Protection Act, 2024, a Data Protection Officer may be a member of an organisation’s staff or may fulfil the role under a service contract. This means organisations can access external DPO expertise without necessarily creating a full-time internal DPO position

What Can a DPO-as-a-Service Provide?

For some organisations, maintaining this expertise internally can be challenging. This is where DPO-as-a-Service can offer a practical solution.

Under Section 70(2) of Botswana’s Data Protection Act, 2024, a Data Protection Officer may be a member of an organisation’s staff or may fulfil the role under a service contract. This means organisations can access external DPO expertise without necessarily creating a full-time internal DPO position.

What Can a DPO-as-a-Service Provide?

An external DPO can provide ongoing privacy expertise and practical support tailored to an organisation’s activities. Rather than treating data protection as a once-off compliance exercise, the DPO helps organisations build and maintain a privacy programme over time.

1. Strengthen Ongoing Compliance

Data protection obligations do not end once policies have been written.

A DPO can help an organisation monitor its compliance programme, identify gaps, review existing practices and provide guidance when new processing activities, technologies or business processes are introduced.

Under Section 72, the DPO’s duties include advising the controller or processor on their obligations under the Act and monitoring compliance with the Act and the organisation’s data protection policies.

2. Access Specialist Privacy Expertise

Data protection involves legal, operational, technical and organisational considerations.

An outsourced DPO gives an organisation access to specialist knowledge without necessarily requiring it to build a dedicated internal privacy team. This can be particularly useful for organisations that process significant amounts of personal or sensitive personal data.

3. Create and Review Privacy Documentation

A privacy programme requires more than a privacy notice.

Depending on an organisation’s activities, a DPO may support the development and review of documentation such as:

Data protection and privacy policies
Records of Processing Activities (RoPA)
Data Protection Impact Assessments (DPIAs)
Data processing agreements
Data retention and deletion procedures
Data subject rights procedures
Privacy notices
Internal privacy procedures and guidelines

A Record of Processing Activities (RoPA) gives an organisation a structured view of how personal data is processed across its operations. It helps identify what personal data is processed, why it is processed, who receives it, where it is transferred and how it is protected.

Not sure what a RoPA is or whether your organisation needs one? Read our guide: [RoPA (Record of Processing Activities): What Is It and Do You Need One?]

4. Support Staff Awareness and Training

Employees are often involved in collecting, accessing, sharing or otherwise processing personal data.

A DPO can help organisations build awareness by providing guidance and training on data protection responsibilities, appropriate handling of personal information and the organisation’s internal privacy procedures.

This aligns with the DPO’s statutory responsibility under Section 72 to monitor awareness-raising and training among personnel involved in processing activities.

5. Support Privacy Risk Assessments

New systems, technologies and processing activities can introduce new privacy risks.

A DPO can advise on Data Protection Impact Assessments (DPIAs) and monitor their performance, as provided for under Section 72 of the Act.

This allows privacy considerations to be addressed before a new process or technology creates unnecessary risk.

6. Provide an Independent Privacy Function

The Act requires a DPO to have functional independence and provides that the DPO should not receive instructions regarding the exercise of their duties. The DPO is also required to report directly to the highest management level of the controller or processor.

An outsourced DPO can therefore give an organisation an independent perspective on its privacy practices while working alongside management and operational teams.

7. Help Organisations Respond to Privacy Incidents

When a privacy incident occurs, organisations need to know what happened, what information may have been affected, what actions need to be taken and whether regulatory or data subject communications may be required.

Having an established DPO function means an organisation has an identified privacy resource that can help coordinate and advise on these matters.

Who Can Benefit from DPO-as-a-Service?

DPO-as-a-Service can be particularly useful for organisations that:

Do not have dedicated internal privacy expertise
Process significant amounts of personal or sensitive personal data
Are developing or introducing new digital systems
Work with multiple third parties or service providers
Need assistance establishing their privacy governance framework
Want ongoing privacy oversight without creating a dedicated internal function
Need an independent privacy professional to advise management

For organisations required to designate a DPO under Section 69, the Act provides that the DPO may fulfil the role through a service contract.

Organisations not required to designate a DPO may also choose to appoint one voluntarily.

Frequently Asked Questions

Who Is a Data Protection Officer?

A Data Protection Officer (DPO) is a privacy professional responsible for advising an organisation on its data protection obligations, monitoring compliance and supporting the organisation in protecting personal data.
Under Section 72 of the Data Protection Act, 2024, the DPO has specific statutory duties, including advising the controller or processor, monitoring compliance, supporting Data Protection Impact Assessments and cooperating with the Information and Data Protection Commission where required.

When Does an Organisation Need a DPO?

Section 69 requires a data controller or data processor to designate a DPO in certain circumstances. These include cases where processing is carried out by a public authority or body, where core activities involve regular and systematic monitoring of data subjects on a large scale, or where core activities involve large-scale processing of sensitive personal data or personal data relating to criminal convictions and offences.
Organisations that do not fall within these circumstances may also choose to designate a DPO voluntarily.

Can a DPO Be Outsourced?

Yes.
Section 70(2) of the Data Protection Act, 2024 provides that a DPO may be a staff member of the data controller or processor, or may fulfil the role’s duties on the basis of a service contract. This gives organisations a clear legal basis for engaging an external DPO.

What Does an Outsourced DPO Actually Do?

An outsourced DPO performs the same statutory functions required of the role. This can include advising management, monitoring compliance, supporting privacy impact assessments, promoting staff awareness and training, and providing guidance on data protection matters.
The exact scope of services is typically defined in the service agreement between the organisation and the external DPO.

Does Having a DPO Mean My Organisation Is Automatically Compliant?

No.
A DPO provides advice, oversight and monitoring, but compliance remains an organisational responsibility.
Having a DPO is one component of a broader data protection programme. Organisations still need appropriate policies, procedures, technical and organisational safeguards, staff awareness and governance processes.

Can a Small Organisation Use DPO-as-a-Service?

Yes. An organisation does not need to employ a full-time privacy professional to establish a DPO function.
For organisations that need specialist expertise but lack the resources or operational need for a dedicated internal position, an external DPO can offer a more flexible approach.

What Should I Look for When Choosing an External DPO?

Look for a DPO or service provider with:
Demonstrable knowledge of data protection law and practice
Understanding of your sector and the types of personal data you process
A clear understanding of the DPO’s independence and statutory responsibilities
Practical experience developing privacy programmes and documentation
The ability to work with management, technical teams and operational staff
A clear service scope with defined responsibilities and deliverables

Privacy Expertise When You Need It

Data protection is an ongoing responsibility. Whether your organisation is establishing its privacy programme, reviewing existing practices or looking for continued oversight, having access to the right expertise can make the process more manageable.

DPO-as-a-Service gives organisations access to dedicated privacy expertise through a service arrangement, helping turn data protection obligations into practical, ongoing processes

Refilwe S. Keatlholetswe

Refilwe is a Data Protection Officer at Doctor On Call, with a background in information systems, cybersecurity and privacy. She focuses on practical privacy governance and data protection within digital healthcare. Through Doctor On Call's Expert Insights, she shares practical perspectives on data protection, privacy and the responsible use of personal information in Botswana's healthcare sector.